- 37 - attributable solely to Christopher. See Washington v. Commissioner, 120 T.C. 137, 147 (2003). Additionally, the following factors weighing against relief are present:10 (1) The items giving rise to the deficiencies also are attributable to petitioner, (2) petitioner had “reason to know”, and (3) petitioner will not suffer economic hardship. Id. Petitioner also argues that respondent made blanket “pro forma” denials of Hoyt investor section 6015 claims. We disagree. Respondent’s internal memoranda contemplate that some Hoyt investors would qualify for section 6015 relief. The memoranda do not reflect a decision to issue blanket denials to all Hoyt investor section 6015 claims. Ms. Sneed testified that she processed claims granting section 6015 relief in other Hoyt investor cases she has reviewed. Furthermore, Ms. Sneed credibly testified that she conducted a full, impartial, and fair evaluation of petitioner’s section 6015 claim. The format of the determination letter denying section 6015 relief for Hoyt investors was unique to the Hoyt cases. This format was provided to Ms. Sneed. Respondent did use uniform 10 The absence of factors weighing against equitable relief does not weigh in favor of granting relief--this is merely neutral. See Washington v. Commissioner, 120 T.C. 137, 149 (2003) (absence of factor weighing in favor of equitable relief does not weigh against granting equitable relief--it is neutral).Page: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
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